Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Penalty u/s 271(1)(c) - the money has been appropriated by ICICI Bank after collection and the assessee has claimed the deficiency in realization as Bad debts. The income of 2% was not considered in profit and loss account by assessee. - The explanations given by the assessee cannot be considered as bonafide and assessee tried to conceal the income by misrepresenting the case - penalty confirmed - AT
Penalty u/s 271(1)(c) - the money has been appropriated by ICICI Bank after collection and the assessee has claimed the deficiency in realization as Bad debts. The income of 2% was not considered in profit and loss account by assessee. - The explanations given by the assessee cannot be considered as bonafide and assessee tried to conceal the income by misrepresenting the case - penalty confirmed - AT
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